TERMS OF SERVICE

1. PREAMBLE & CONTRACTUAL RELATIONSHIP

1.1. Parties & Identity This Terms of Service Agreement ("Agreement") constitutes a legally binding contract between:

• The Platform: 01 Festivals Limited, a company incorporated under the laws of the Hong Kong Special Administrative Region ("Hong Kong") (Company Registry No. 76929555) (hereinafter referred to as "The Platform", "We", "Us", or "Our"); and
• The User: Any individual or legal entity accessing, browsing, registering an account on, or purchasing tickets through our mobile application or website (hereinafter referred to as "The Attendee", "You", or "Your").

1.2. Acceptance of Terms By accessing the Platform or purchasing a ticket, You expressly acknowledge that You have read, understood, and agreed to be bound by this Agreement. If You do not agree to these terms, You must immediately cease using the Platform.

1.3. Nature of Our Services (Agency Disclosure) You explicitly acknowledge and agree that:

• (a) Commercial Agent Status: The Platform operates strictly as a disclosed commercial agent and third-party technology provider on behalf of event organizers, promoters, venues, or artists (collectively, "The Organizer").
• (b) Scope of Service: Our obligations to You are limited to providing the software infrastructure to facilitate the booking and payment transmission. We do not organize, promote, produce, manage, or control the events listed on the Platform.
• (c) No Principal Liability: We are not responsible for the content, quality, safety, legality, or actual execution of the events. Any descriptions, schedules, or visual representations of events are provided directly by The Organizer, for which The Platform bears no liability under the Trade Descriptions Ordinance to the fullest extent permitted by law.

1.4. Dual Contract Formation To ensure clarity regarding liability, You acknowledge the formation of two distinct legal contracts when using our services:

2. SERVICE AVAILABILITY ("BETA" DISCLAIMER)

2.1. "As Is" and "As Available" Basis You expressly acknowledge and agree that the Platform is currently in a "Beta" or developmental phase ("MVP Status"). To the fullest extent permitted by Hong Kong law, the Services are provided on an "AS IS" and "AS AVAILABLE" basis, with all faults and without warranty of any kind, whether express or implied.

2.2. No Guarantee of Continuity While 01 Festivals Limited employs reasonable care and skill in maintaining the Platform, We do not warrant that:

• (a) The Platform will be uninterrupted, timely, secure, or error-free;
• (b) The Platform will be compatible with Your specific device or operating system; or
• (c) Any specific defects or bugs will be corrected immediately.

2.3. Liability for Technical Failure You agree that We shall not be liable for any direct or indirect loss, loss of opportunity (e.g., failure to secure a ticket), or damages arising from:

• (a) System downtime, server crashes, or maintenance windows;
• (b) Data loss or corruption resulting from the Beta nature of the software; or
• (c) Your inability to access the Platform during periods of high traffic (e.g., ticket launch queues).

3. PAYMENT PROCESSING & DATA SECURITY

3.1. Third-Party Payment Processor (Stripe) We use Stripe Payments Hong Kong Limited ("Stripe") as our exclusive third-party payment processor. By making a purchase, You agree to be bound by Stripe’s Services Agreement. You acknowledge that 01 Festivals Limited acts only to transmit transaction details and does not process the financial transaction itself.

3.2. PCI-DSS Compliance & Data Handling To ensure the security of Your financial data:

• (a) No Storage of Sensitive Data: The Platform utilizes "Tokenization" technology. We never view, access, or store Your full credit card number (PAN) or CVV/CVC code on Our servers.
• (b) Compliance Responsibility: You acknowledge that responsibility for compliance with the Payment Card Industry Data Security Standard (PCI-DSS) rests exclusively with Stripe.
• (c) Liability for Breaches: To the extent permitted by law, 01 Festivals Limited is not liable for any data breach, hacking incident, or unauthorized access that occurs within Stripe’s infrastructure or as a result of Your failure to secure Your own device.

3.3. Strong Customer Authentication (3D Secure) Transactions on the Platform are subject to bank-mandated security protocols, including "3D Secure" (SCA).

• (a) Verification Requirement: You are solely responsible for verifying the transaction with Your issuing bank (e.g., via SMS code or banking app).
• (b) Failed Transactions: If You fail to complete the 3D Secure verification within the time limit, the transaction will be declined. We accept no liability for tickets lost to other buyers during the time it takes You to resolve verification issues with Your bank.

4. FEES, PAYMENTS & "GROSS-UP" CALCULATION

4.1. Components of the Total Price You acknowledge that the total price paid by You ("Total Transaction Amount") is a consolidated sum comprising three distinct components:

• (a) Ticket Face Value: The revenue remitted to The Organizer;
• (b) Platform Service Fee: The fee payable to 01 Festivals Limited for the license to use our software and booking infrastructure; and
• (c) Payment Processing Fee: The costs levied by third-party financial institutions (e.g., Stripe, Banks) to process the digital transaction.

4.2. Agreement to "Gross-Up" Calculation Method You expressly agree to the application of a "Gross-Up" pricing algorithm. You acknowledge that this method is necessary to ensure The Organizer receives the exact Ticket Face Value. The Total Transaction Amount is calculated as follows:

Total Charge = (Face Value + Platform Fee + Fixed Fee) / (1 - Processing Fee %)

By proceeding with the purchase, You irrevocably waive any right to dispute the mathematical method used to calculate the final price, acknowledging that the resulting Total Transaction Amount may be marginally higher than a simple additive sum of the percentages due to the compounding nature of the processing fee absorption.

4.3. Variable Processing Rates You acknowledge that Processing Fees are variable and determined by the nature of the card or payment method used. While estimated rates are provided for reference (e.g., ~3.4% + HK2.35 for HK cards; ~3.9% + HK2.35 for international/AMEX cards), You agree to pay the final calculated amount displayed at checkout regardless of the specific underlying rate applied.

4.4. STRICTLY NON-REFUNDABLE FEES ("Service Rendered" Clause) THIS CLAUSE LIMITS YOUR RIGHTS TO A REFUND. PLEASE READ CAREFULLY.

• (a) Distinct Service: You acknowledge that the Platform Service Fee and Processing Fee represent consideration for a service (the technical processing of the booking and delivery of the digital ticket) that is distinct from the Event itself.
• (b) Completion of Service: Our service to You is deemed fully performed and completed the moment the transaction is processed and a confirmation is generated.
• (c) No Refunds: Consequently, the Platform Service Fee and Processing Fees are strictly non-refundable under any circumstances, including but not limited to:

• (i) Cancellation, postponement, or abandonment of the Event by The Organizer;
• (ii) "Acts of God," weather conditions, or Force Majeure events; or
• (iii) Your personal inability to attend the Event.

• (d) Refund Scope: In the event of a valid refund claim (e.g., Event Cancellation), Your refund will be limited strictly to the Ticket Face Value (subject to The Organizer’s funds availability), and will exclude all Platform and Processing Fees.

4.5. Currency and Exchange Rates All transactions are settled in Hong Kong Dollars (HKD) unless expressly stated otherwise. If You use a non-HKD payment method, Your issuing bank will determine the exchange rate and may charge additional foreign transaction fees. 01 Festivals Limited is not liable for any discrepancies between the price displayed and the amount deducted from Your account due to exchange rate fluctuations.

5. DEFERRED PAYMENT PLANS ("50/50" & INSTALLMENTS)

5.1. Irrevocable Continuous Payment Authority (CPA) By opting for the "50/50 Deposit" or any deferred payment scheme, You grant 01 Festivals Limited an irrevocable Continuous Payment Authority. You explicitly authorize Us to:

• (a) Store Your payment credentials securely (via Stripe); and
• (b) Automatically initiate a second transaction for the outstanding balance on the scheduled date without further consent or action required from You.

5.2. Payment Structure & Fee Allocation (Front-Loaded Fees) To protect Platform operations, You acknowledge that the payment structure is "Front-Loaded":

• (a) First Installment (The Deposit): Charged immediately. This sum includes 50% of the Ticket Face Value PLUS 100% of all non-refundable Platform Service Fees and Processing Fees.
• (b) Second Installment (The Balance): Charged automatically at the scheduled interval (typically 72 hours prior to the Event). This sum includes the remaining 50% of the Ticket Face Value and any specific administrative surcharges applicable to the installment plan.
• (c) No Interest: This payment plan is an interest-free accommodation and does not constitute a loan or credit facility.

5.3. Automatic Collection & Retry Protocol

• (a) Schedule: The Balance will be charged exactly at the time specified in Your order confirmation (default: 72 hours / 3 days prior to the Event start time).
• (b) Reminder Service: While We may attempt to send a reminder email approximately 4 days prior to the charge, it is Your sole responsibility to ensure sufficient funds are available. Non-receipt of a reminder does not excuse payment obligations.
• (c) Retry Logic: If the initial capture fails, Our system is authorized to re-attempt the charge up to three (3) times (e.g., at 3 days, 2 days, and 1 day prior to the event).

5.4. DEFAULT, TICKET INVALIDATION & LIQUIDATED DAMAGES THIS CLAUSE AFFECTS YOUR LEGAL RIGHTS. PLEASE READ CAREFULLY. If the Second Installment fails after the final system attempt:

• (a) Automatic Invalidation: Your ticket status will immediately convert to "FAILED/UNPAID." The QR Code associated with Your booking will be deactivated and will not scan at the venue.
• (b) Forfeiture of Deposit (Liquidated Damages): You acknowledge that by holding the inventory for You, the Platform and Organizer have suffered a loss of opportunity to sell that ticket to another buyer. Therefore, in the event of default, the First Installment (Deposit) shall be retained entirely by 01 Festivals Limited. You agree that this retention constitutes liquidated damages (a genuine pre-estimate of loss) and an administrative fee, NOT a penalty.
• (c) No Refund: The First Installment is strictly non-refundable under any circumstances if the Second Installment is not completed.

5.5. Right to Cure (Manual Reinstatement) At Our sole discretion, We may offer a "Right to Cure" allowing You to manually pay the outstanding balance via the "My Tickets" dashboard or at the venue door. However:

• (a) We do not guarantee that the ticket inventory will still be available (e.g., if the event has reached legal capacity).
• (b) Reinstatement may be subject to an additional "Late Payment Administration Fee."

6. CHARGEBACKS & DISPUTE RESOLUTION

6.1. Agreement to Dispute Resolution Process Before contacting Your bank or credit card issuer to request a chargeback or reversal of payment ("Chargeback"), You agree to first contact 01 Festivals Limited Support to attempt to resolve the issue amicably. You acknowledge that initiating a Chargeback without first contacting Us constitutes a material breach of this Agreement.

6.2. Waiver of Specific Chargeback Reasons You expressly acknowledge that the "Second Installment" (where applicable) and the initial ticket purchase are authorized transactions. By accepting this Agreement, You waive Your right to initiate a Chargeback for the following reasons, and agree that such Chargebacks are invalid:

• (a) "Unrecognized Transaction": Given that You have completed 3D Secure (SCA) verification and received a confirmation email.
• (b) "Service Not Received" (Event Quality): As We are the commercial agent, not the Organizer, dissatisfaction with the Event (e.g., lineup changes, sound quality, venue conditions) is not a valid basis for a Chargeback against The Platform. Your recourse is solely against The Organizer.
• (c) "Forgot to Cancel": Failure to cancel a payment plan or deferred payment prior to the automated charge date.

6.3. "Friendly Fraud" & Material Breach We take "Friendly Fraud" (purchasing a ticket, attending/holding the inventory, and then disputing the charge) seriously.

• (a) Definition: If You initiate a dispute for a transaction where:

• (i) 3D Secure verification was successfully validated;
• (ii) The ticket was scanned (used) at the venue; or
• (iii) The ticket remained valid and available for Your use (regardless of whether You attended); We classify this as "Friendly Fraud."

• (b) Consequences: In the event of Friendly Fraud, We reserve the right to:

• (i) Permanently suspend Your account and blacklist Your payment details, IP address, and device ID from the Platform;
• (ii) Cancel any other active tickets You hold for future events without refund; and
• (iii) Initiate legal proceedings to recover the disputed amount plus all associated legal fees and administrative costs.

6.4. Authorization to Release Evidence In the event of a dispute, You explicitly authorize 01 Festivals Limited to provide the following evidence to the relevant financial institution, payment processor (Stripe), or legal authority to prove the validity of the debt:

• (a) Access Logs: IP addresses, device fingerprints, and login timestamps;
• (b) Communication Logs: Email delivery receipts (e.g., SendGrid/AWS SES logs) proving receipt of ticket confirmation and reminders;
• (c) Usage Data: Entry scan logs (timestamps of when the QR code was scanned at the venue); and
• (d) Terms Acceptance: Digital records of Your acceptance of these Terms (the "Clickwrap" timestamp).

6.5. Administrative Fee for Invalid Disputes If a Chargeback is decided in Our favor by the bank or payment processor, You agree to pay 01 Festivals Limited an Maximum Administrative Dispute Fee permitted by law to cover the administrative burden of contesting the invalid claim. You authorize Us to charge this amount to Your stored payment method.

7. REFUNDS, CANCELLATIONS & WEATHER POLICY

7.1. All Sales Final (No Cooling-Off Period) You expressly acknowledge that:

• (a) Statutory Exemption: Under Hong Kong law, the supply of services related to leisure activities, where the contract provides for a specific date of performance, is exempt from statutory cooling-off periods (if any apply).
• (b) No Refunds/Exchanges: Unless the Event is cancelled or materially altered by The Organizer, all sales are final. We do not offer refunds, exchanges, or cancellations for:

• (i) Change of mind or personal schedule conflicts;
• (ii) Medical reasons or illness; or
• (iii) Disappointment with the line-up, artist performance, or venue facilities.

7.2. Adverse Weather Policy (Typhoon & Black Rain) Events in Hong Kong are subject to weather-related risks. The following protocols apply unless The Organizer specifies otherwise:

• (a) Signal T8 / Black Rain: If the Hong Kong Observatory issues a Typhoon Signal No. 8 (or higher) or a Black Rainstorm Warning effective at the time of the Event, the Event may be cancelled or rescheduled.
• (b) Lower Signals: The Event will generally proceed as scheduled during Typhoon Signals No. 1 or 3, or Amber/Red Rainstorm Warnings. Refunds are not provided if You choose not to attend due to non-critical weather conditions.
• (c) Service Fee Retention: In the event of a weather-related cancellation, Your refund will be limited to the Ticket Face Value. You acknowledge that Our technical service (booking processing) has been fully performed, and therefore Platform Fees and Processing Fees remain strictly non-refundable.

7.3. Event Cancellation & Refund Logistics In the rare event of a cancellation by The Organizer:

• (a) Funds Held by Platform: If 01 Festivals Limited is still in possession of the ticket proceeds at the time of cancellation, We will facilitate a refund of the Ticket Face Value to Your original payment method on behalf of The Organizer.
• (b) Funds Released to Organizer: If We have already settled funds to The Organizer (as per our commercial agreement with them), 01 Festivals Limited has no legal power to issue a refund. In this scenario:

• (i) We will notify You of The Organizer’s direct contact details; and
• (ii) You must seek recourse and repayment directly from The Organizer.

• (c) Liability Waiver: You agree that 01 Festivals Limited shall not be liable for any failure by The Organizer to refund ticket proceeds that have already been settled to them.

7.4. Force Majeure Neither the Platform nor the Organizer shall be liable for failure to perform their obligations if such failure is a result of Acts of God (including fire, flood, earthquake, storm, hurricane, or other natural disaster), war, invasion, act of foreign enemies, hostilities (regardless of whether war is declared), civil war, rebellion, revolution, insurrection, military or usurped power or confiscation, terrorist activities, nationalization, government sanction, blockage, embargo, labor dispute, strike, lockout, or interruption or failure of electricity or telephone service ("Force Majeure Event").

8. TICKET USAGE, RESTRICTIONS & CONDUCT

8.1. Nature of the Ticket (Revocable License) You acknowledge that a Ticket is a personal, revocable license which may be withdrawn, and admission refused, at any time. A Ticket is not a property right and creates no tenancy or property interest in the Venue.

• (a) Refusal of Admission: The Organizer and Venue Management reserve the right to refuse admission or eject any person, without refund, whose conduct is deemed disorderly, who uses vulgar or abusive language, or who fails to comply with Venue rules.
• (b) Search & Security: You consent to a reasonable search of Your person and belongings upon entry. Failure to consent will result in denial of entry without refund.

8.2. STRICT ANTI-SCALPING & RESALE POLICY THIS CLAUSE IS STRICTLY ENFORCED TO PROTECT FANS AND EVENT INTEGRITY.

• (a) Prohibition on Commercial Resale: The resale, or attempted resale, of any Ticket for a price higher than the original Total Transaction Amount ("Speculative Scalping") is strictly prohibited.
• (b) Unauthorized Platforms: You agree that 01 Festivals Limited is the sole authorized ticket agent. We reserve the right to monitor secondary markets (including but not limited to Viagogo, StubHub, Carousell, and Facebook Marketplace).
• (c) Consequence of Breach: Any Ticket found to be listed, sold, or transferred in violation of this Clause shall be deemed void ab initio (invalid from the start). We reserve the right to:

• (i) Cancel the Ticket without prior notice;
• (ii) Refuse entry to the holder of the voided Ticket; and
• (iii) Retain the full purchase price as liquidated damages for the breach of contract and the administrative cost of policing the inventory.

8.3. Restrictions on Deferred Payment Tickets ("50/50 Plans") To prevent fraud and technical errors, Tickets purchased under a Deferred Payment Plan or Deposit Scheme are subject to stricter controls:

• (a) Non-Transferable During Deposit Phase: A Ticket is STRICTLY NON-TRANSFERABLE while it is in a "Partially Paid" or "Deposit" status. You may not sell, gift, or reassign a Ticket until the Second Installment has been successfully captured and the balance is paid in full.
• (b) Voiding of Transferred Deposits: If We detect that a Deposit-status ticket has been transferred or sold to a third party, We reserve the right to immediately invalidate the booking and forfeit the deposit.

8.4. Valid Ticket Presentation

• (a) QR Code Security: You are solely responsible for the security of Your ticket's QR code. You acknowledge that the first QR code scanned at the gate will be the only one authorized for entry. Duplicate scans (e.g., from screenshots shared with friends) will be rejected.
• (b) ID Matching: For specific high-demand events, The Organizer reserves the right to require a valid government-issued photo ID (HKID or Passport) matching the name on the Ticket. Failure to present matching ID may result in refusal of entry without refund.

9. ENTRY CONDITIONS, CONDUCT & SAFETY PROTOCOLS

9.1. Age Verification & Identification

• (a) Mandatory ID: You acknowledge that many Events listed on the Platform are age-restricted (e.g., 18+). You must present valid, physical, government-issued photo identification (e.g., Hong Kong Identity Card, Passport, or other recognized travel document) upon request.
• (b) No Copies: Photocopies, digital scans, or photos of IDs on mobile phones are not accepted as valid proof of age.
• (c) Consequence of Failure: If You are refused entry by Venue security for failure to provide valid ID or for not meeting the age requirement, You are strictly NOT entitled to a refund.

9.2. Security Search & Prohibited Items

• (a) Consent to Search: As a condition of entry, You consent to a reasonable search of Your person and belongings (including bags) by security personnel.
• (b) Prohibited Items: The Organizer reserves the right to prohibit items including but not limited to:

• (i) Professional cameras or recording equipment;
• (ii) Outside food and beverage (including alcohol);
• (iii) Illegal substances, drugs, or drug paraphernalia;
• (iv) Weapons, sharp objects, or any item deemed dangerous.

• (c) Confiscation & Disposal: Prohibited items found during a search may be confiscated, discarded, or disposed of by security personnel without compensation or liability to replace the item.

9.3. Refusal of Entry (Intoxication & Health) The Organizer and Venue Management reserve the absolute right to refuse admission to, or eject, any person who:

• (a) Appears to be intoxicated or under the influence of drugs;
• (b) Exhibits symptoms of infectious disease (subject to current Government health regulations); or
• (c) Behaves in a manner that compromises the safety or enjoyment of others. In such cases, no refund will be issued.

9.4. ZERO TOLERANCE POLICY (Harassment) We maintain a Zero Tolerance Policy regarding harassment.

• (a) Scope: This policy applies to behavior towards Our support staff (via email, chat, or social media) and on-site staff at the Event.
• (b) Prohibited Conduct: Aggressive behavior, profanity, threats, sexual harassment, or hate speech will not be tolerated.
• (c) Consequences: We reserve the right to:

• (i) Immediately terminate Your communication;
• (ii) Permanently ban Your account from the Platform; and
• (iii) Revoke any active tickets in Your possession without refund.

9.5. Media Release & Image Rights By attending the Event, You acknowledge that You may be filmed, photographed, or recorded. You grant the Platform and The Organizer the irrevocable, worldwide, royalty-free right to use Your image, likeness, and voice in promotional materials, after-movies, and social media content, without compensation or further approval.

10. LIMITATION OF LIABILITY THIS SECTION LIMITS OUR LEGAL LIABILITY TO YOU. PLEASE READ CAREFULLY.

10.1. Exclusion of Consequential Damages To the fullest extent permitted by Hong Kong law, 01 Festivals Limited (including its directors, officers, employees, and agents) shall not be liable to You for any:

• (a) Indirect, special, incidental, punitive, or consequential damages;
• (b) Loss of profits, data, goodwill, or business opportunity;
• (c) Travel or accommodation costs (e.g., wasted flights or hotels) resulting from Event cancellation; or
• (d) Damages for personal distress, disappointment, or "loss of enjoyment."

10.2. The Liability Cap In the event that 01 Festivals Limited is found liable to You for any claim arising out of or in connection with these Terms or Your use of the Platform (whether in contract, tort, negligence, or otherwise), Our total aggregate liability shall be strictly limited to the total "Platform Service Fees" paid by You for the specific transaction in dispute.

• Note: This cap explicitly excludes the Ticket Face Value, as the recovery of the Face Value is a matter solely between You and The Organizer.

10.3. Statutory Exceptions Nothing in this Agreement excludes or limits Our liability for:

• (a) Death or personal injury caused by Our negligence (as required by the Control of Exemption Clauses Ordinance);
• (b) Fraud or fraudulent misrepresentation; or
• (c) Any other liability which cannot be excluded or limited by Hong Kong law.

10.4. Indemnification You agree to defend, indemnify, and hold harmless 01 Festivals Limited from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal and accounting fees) arising out of or in any way connected with:

• (a) Your access to or use of the Platform;
• (b) Your violation of these Terms;
• (c) Your conduct at an Event (including damage to property or injury to third parties); or
• (d) Your infringement of any third-party right, including intellectual property or privacy rights.

10.5. One (1) Year Time Bar You agree that any claim or cause of action arising out of or related to use of the Service or these Terms must be filed within one (1) year after such claim or cause of action arose. Otherwise, such claim is permanently barred, notwithstanding any longer statutory limitation period provided by Hong Kong law (typically 6 years).

11. GOVERNING LAW & DISPUTE RESOLUTION

11.1. Governing Law These Terms shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region.

11.2. Jurisdiction You agree to submit to the exclusive jurisdiction of the courts of Hong Kong to resolve any dispute or claim arising from these Terms.

11.3. Severability If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction (e.g., if a specific liability cap is deemed unreasonable), the validity, legality, and enforceability of the remaining provisions shall not in any way be affected or impaired.

11.4. Entire Agreement & Language

• (a) Entire Agreement: These Terms constitute the entire agreement between You and 01 Festivals Limited regarding the Service and supersede all prior agreements or understandings.
• (b) Prevailing Language: In the event of any discrepancy between the English version and any translated version (e.g., Traditional Chinese) of these Terms, the English version shall prevail.

12. AMENDMENTS & ASSIGNMENT

12.1. Right to Modify We reserve the right to modify or replace these Terms at any time. If a revision is material, We will provide at least 30 days' notice via email or an in-app notification.

• (a) Continued Use: Your continued use of the Platform following the posting of any changes constitutes acceptance of those changes.
• (b) Check Responsibility: It is Your responsibility to check this Agreement periodically for changes.

12.2. Assignment You may not assign or transfer these Terms, by operation of law or otherwise, without Our prior written consent. 01 Festivals Limited may assign these Terms (and transfer Your account data) to a subsidiary, parent company, or a successor entity in the event of a merger, acquisition, or asset sale, without restriction.

13. CONTACT INFORMATION

For legal notices or support inquiries regarding these Terms, please contact us at:

• 01 Festivals Limited
• Email: info@01festivals.com

PRIVACY POLICY & PERSONAL INFORMATION COLLECTION STATEMENT (PICS)

1. PERSONAL INFORMATION COLLECTION STATEMENT (PICS)

1.1. Statement of Purpose & Compliance This Personal Information Collection Statement ("PICS") is made in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region ("PDPO"). 01 Festivals Limited ("We", "The Platform") is committed to protecting the privacy, confidentiality, and security of the personal information we hold. This PICS sets out the purposes for which Your personal data is collected and how it will be used.

1.2. Purpose of Collection (Why We Need Your Data) We collect Your personal data for specific, lawful purposes directly related to our function as a commercial ticketing agent. You acknowledge that providing the data listed in Section 1.3 is mandatory for the formation of the contract and the purchase of tickets. Failure to provide accurate data may result in Our inability to process Your transaction or The Organizer's refusal to grant You entry. The specific purposes are:

• (a) Transaction Processing: To process payments, verify credit card authorization (via third parties), and execute deferred payment plans (including the "50/50" split-payment scheme).
• (b) Identity Verification & Access Control: To verify Your identity at the event venue (e.g., matching Your Name/QR Code to the digital guest list) and ensure only valid ticket holders gain entry.
• (c) Fraud Prevention & Security: To detect and prevent "Friendly Fraud," unauthorized chargebacks, scalping, and money laundering. This involves analyzing IP addresses, device fingerprints, and transaction velocity.
• (d) Operational Communication: To send essential service notifications, including transaction receipts, event cancellations/changes, and critical payment reminders for deferred payment plans.
• (e) Legal Compliance: To comply with valid legal requests from Hong Kong law enforcement, regulatory bodies, or the Courts.

1.3. Classes of Data Collected We adhere to the principle of Data Minimization and only collect data necessary to fulfill the purposes outlined above. Based on Your interaction with the Platform, We may collect:

• (a) Identity Data: First and Last Name (as it appears on Your government ID) for ticket verification.
• (b) Contact Data: Valid Email Address (for account login, ticket delivery, and dispute resolution) and Mobile Phone Number (optional, for SMS reminders).
• (c) Authentication Data: Passwords, which are strictly salted and hashed using industry-standard algorithms (e.g., bcrypt) before storage. We do not store and cannot view Your plaintext password.
• (d) Transaction Meta-Data: Transaction reference numbers, payment dates, and partial card details (e.g., last 4 digits and card brand) provided by Stripe for receipt generation.
• (e) Technical & Usage Data:

• Device Fingerprints: Device model, OS version, and unique identifiers (used strictly for fraud detection).
• Network Data: IP addresses and access timestamps (stored temporarily for security auditing).
• Ticket Assets: Unique QR Codes generated for Your specific booking.

1.4. Data We Strictly DO NOT Store ("Negative List") To maximize security and limit liability, the Platform adheres to a strict "Non-Persistence" policy for sensitive financial and personal documentation. We NEVER store, process, or have access to the following on Our own servers:

• (a) Full Payment Credentials: Full credit card numbers (PAN) or CVV/CVC codes. These are handled exclusively by Stripe via direct tokenization.
• (b) Government ID Copies: We do not store digital scans or images of Your HKID, Passport, or Driver's License.
• (c) Persistent Full IP Logs: While we use IP data for real-time fraud checks, we do not retain long-term historical logs of your browsing history beyond what is necessary for security auditing and dispute resolution.

2. DATA TRANSFER & THIRD-PARTY DISCLOSURE

2.1. Transfer to Event Organizers (The "Necessity" Clause) You expressly acknowledge and agree that 01 Festivals Limited acts as a commercial agent. To fulfill the contract of sale and ensure Your admission to the Event, it is strictly necessary for Us to transfer specific Personal Data to the third-party Event Organizer ("The Organizer").

• (a) Data Transferred: This includes Your First Name, Last Name, Ticket Unique Identifier (UUID), and Email Address.
• (b) Purpose of Transfer: This transfer is solely for the purposes of guest list management, identity verification at the venue, and communicating essential event updates (e.g., cancellation notices).
• (c) Consent: By purchasing a ticket, You provide Your explicit consent to this data transfer.

2.2. Organizer Liability Disclaimer (Separation of Data Users) PLEASE READ CAREFULLY: Once Your data is successfully transmitted to The Organizer, The Organizer becomes a separate and independent "Data User" under the PDPO.

• (a) No Control: 01 Festivals Limited has no control over, and assumes no responsibility for, The Organizer’s internal privacy practices, data security measures, or marketing policies.
• (b) Marketing Compliance: You acknowledge that any direct marketing communications (e.g., newsletters, promotions) sent to You by The Organizer are subject to The Organizer's own policies and the Unsolicited Electronic Messages Ordinance (Cap. 593). We are not liable for any spam or unsolicited messages sent by The Organizer.
• (c) Liability Release: You hereby release 01 Festivals Limited from any liability, claims, or damages arising from the misuse, loss, or mishandling of Your data by The Organizer.

2.3. Trusted Third-Party Service Providers (Sub-Processors) We engage trusted third-party service providers ("Data Processors") to perform technical functions on Our behalf. You consent to the transfer of Your data to the following providers (or their functional equivalents):

• (a) Stripe (Payment Processing): Used for PCI-DSS compliant payment execution and Know Your Customer (KYC) checks. Data shared includes Payment Tokens, Customer Name, and Email.
• (b) Amazon Web Services (AWS): Used for secure cloud infrastructure and asset storage (S3). Data stored includes Ticket QR Code images and event imagery.
• (c) MongoDB Atlas: Used as the primary encrypted database provider. Data stored includes User Profiles, Order History, and Hashed Passwords.
• (d) Redis: Used for high-speed caching and session management. Data stored includes temporary session tokens and API rate-limiting logs.

2.4. Cross-Border Data Transfer You acknowledge that the third-party service providers listed in Clause 2.3 (e.g., AWS, Stripe, MongoDB) may maintain servers located outside of Hong Kong (e.g., in Singapore, Japan, or the United States). By using the Platform, You explicitly consent to the transfer of Your data to jurisdictions outside of Hong Kong for storage and processing, acknowledging that these jurisdictions may have different data protection laws than Hong Kong.

2.5. Legal & Regulatory Disclosure We reserve the right to disclose Your personal data without Your prior consent if We have a good faith belief that such disclosure is necessary to:

• (a) Comply with a valid legal inquiry, subpoena, or court order from Hong Kong courts or law enforcement agencies;
• (b) Assist in the prevention or detection of a crime (including credit card fraud or money laundering); or
• (c) Protect the rights, property, or safety of 01 Festivals Limited, our users, or the public.

3. DIRECT MARKETING & CONSENT

3.1. Requirement for Consent (The "Opt-In" Standard) In accordance with Part 6A of the PDPO, 01 Festivals Limited intends to use Your personal data for direct marketing purposes. However, We may not do so unless We have received Your consent or an indication of no objection. We will always seek this consent via a specific "Opt-In" mechanism (e.g., a checkbox) at the point of registration or checkout.

3.2. Scope of Marketing (Classes of Services) If You provide consent, We may use Your Contact Data (Email, Name, Phone Number) to send You promotional materials via email, SMS, or app push notifications regarding:

• (a) Platform Updates: New features, app improvements, or loyalty programs;
• (b) Event Recommendations: Concerts, festivals, nightlife events, art exhibitions, and cultural activities listed on the Platform; and
• (c) Exclusive Offers: "Early Bird" tickets, discount codes, and partner promotions relevant to the ticketing sector.

3.3. Transfer to Event Organizers for Marketing (Crucial Distinction) PLEASE READ CAREFULLY: By opting into the "Event Updates & Partner Offers" preference, You provide explicit written consent for Us to transfer Your Contact Data to the specific Event Organizer of the events You purchase tickets for, so that they may market similar future events to You directly.

• (a) Separate Data User: You acknowledge that once this data is transferred, The Organizer becomes a separate Data User.
• (b) Unsubscribing from Organizers: If You wish to stop receiving marketing from a specific Organizer, You must unsubscribe directly through their communication channels. Unsubscribing from 01 Festivals Limited does not automatically unsubscribe You from the third-party Organizer’s list, as We do not control their database.
• (c) Liability Release: We are not responsible for the content, frequency, or compliance of marketing messages sent by third-party Organizers.

3.4. Service vs. Marketing Communications To ensure the integrity of the Service, specific "Operational Communications" are exempt from the marketing opt-out. Even if You unsubscribe from marketing, You will continue to receive:

• (a) Transaction receipts and booking confirmations;
• (b) Payment reminders (specifically for deferred "50/50" payment plans);
• (c) "Know Before You Go" guides and safety notices for upcoming events You have booked; and
• (d) Notices regarding changes to these Terms or the Privacy Policy.

3.5. Withdrawal of Consent (Unsubscribe) You may withdraw Your consent for the Platform’s direct marketing at any time, free of charge, by:

• (a) Clicking the "Unsubscribe" link found at the bottom of any marketing email; or
• (b) Adjusting the "Notification Preferences" in your App Settings. We will process your request within 10 working days as required by law.

4. COOKIES, LOCAL STORAGE & TRACKING

4.1. Consent to Use By accessing or using the Platform, You expressly consent to the placement of Cookies, Pixels, Beacons, and Local Storage files ("Tracking Technologies") on Your device. You acknowledge that these technologies are essential for the Platform's security, functionality, and payment processing capabilities.

4.2. Categories of Tracking Technologies We classify our usage of Tracking Technologies into the following legally distinct categories:

• (a) Strictly Necessary (Essential) Cookies: These are vital for the Platform to function. Without them, services you have asked for (such as the Shopping Cart, "50/50" Payment execution, and Secure Login) cannot be provided. You cannot opt-out of these cookies.
• (b) Security & Fraud Prevention: We utilize specialized scripts (including Redis session tokens and Stripe device fingerprinting) to:

• (i) Maintain Your active user session;
• (ii) Detect and block "Brute Force" login attacks; and
• (iii) Identify high-risk transactions to prevent credit card fraud.

• (c) Performance & Analytics: We may use third-party tools (e.g., Google Analytics, Firebase) to collect aggregated, anonymous data on how users interact with the App (e.g., "Crash Reporting" or "Page Load Speeds"). This data helps us improve Platform stability.

4.3. Third-Party Cookies (Liability Disclaimer) You acknowledge that trusted third parties may place their own cookies on Your device when You use the Platform. We do not control these third parties.

• (a) Stripe & Payments: Stripe places cookies to detect fraud and ensure PCI-DSS compliance. Disabling these may cause Your payment to fail.
• (b) Google reCAPTCHA: We use reCAPTCHA to protect the Platform from spam and abuse. Use of this service is subject to Google's Privacy Policy and Terms of Use.

4.4. Managing Your Preferences Most mobile devices and web browsers accept cookies automatically. You can choose to block or delete cookies via Your browser or device settings. However, You explicitly acknowledge that blocking "Strictly Necessary" or "Security" cookies will render the Platform unusable, preventing You from purchasing tickets or accessing Your account. 01 Festivals Limited is not liable for any transaction failure resulting from Your local device settings.

5. DATA SECURITY & RETENTION

5.1. Security Measures ("Practicable Steps") We take all reasonably practicable steps to protect Your personal data against unauthorized or accidental access, processing, erasure, loss, or use. Our security architecture includes:

• (a) Encryption: Industry-standard Transport Layer Security (TLS/SSL) is used for all data in transit.
• (b) Hashing: Passwords are never stored in plaintext. We use bcrypt (a cryptographic hashing function) with unique salts.
• (c) Infrastructure: Our database is hosted on MongoDB Atlas using enterprise-grade security configurations, including IP whitelisting and encryption-at-rest.
• (d) Access Control: Internal access to user data is strictly restricted to authorized employees with a legitimate business need, subject to confidentiality agreements.

5.2. "No Guarantee" & Risk Acknowledgment While We strive to use commercially acceptable means to protect Your Personal Data, You acknowledge that:

• (a) Internet Risk: No method of transmission over the Internet, or method of electronic storage, is 100% secure.
• (b) Assumption of Risk: You provide Your personal data at Your own risk.
• (c) Liability Disclaimer: To the fullest extent permitted by law, 01 Festivals Limited disclaims any liability for a data breach, hacking incident, or unauthorized disclosure caused by:

• (i) Sophisticated cyber-attacks exceeding standard industry defenses;
• (ii) Vulnerabilities in third-party software (e.g., OS bugs); or
• (iii) Your failure to secure Your own device or password.

5.3. Prohibition on AI Training (Data Sovereignty) Your privacy is paramount. We strictly prohibit third parties, scrapers, or crawlers from using data available on our Platform (including user profiles, reviews, or image data) to train Artificial Intelligence (AI), Large Language Models (LLM), or Machine Learning systems.

5.4. Data Retention Policy (How Long We Keep It) In accordance with Data Protection Principle 2 (DPP2), We retain Your personal data only for as long as necessary to fulfill the purpose for which it was collected.

• (a) Active Accounts: Data is retained indefinitely while Your account remains active to provide the Service.
• (b) Transaction Records (7 Years): To comply with the Hong Kong Inland Revenue Ordinance (Cap. 112), We are legally required to retain financial and transaction records (including invoices and order history) for a minimum of 7 years for auditing and tax purposes.
• (c) Inactive/Deleted Accounts: Upon Your request to delete Your account, Your personal identifiers (Name, Email) will be anonymized or permanently erased within 90 days, except where retention is required by law (see clause 5.4b).

6. ACCESS & CORRECTION RIGHTS

6.1. Your Statutory Rights Under the Personal Data (Privacy) Ordinance, You have the right to request access to and correction of Your personal data held by Us. This includes the right to:

• (a) Check: Ascertain whether We hold personal data about You.
• (b) Access: Request a copy of the personal data We hold about You ("Data Access Request").
• (c) Correct: Request that We correct any of Your personal data that is inaccurate ("Data Correction Request").

6.2. Contact Officer All requests for data access, correction, or deletion should be addressed to our Data Protection Officer at: support@circleticket.com

6.3. Response Time & Fees

• (a) Response Time: We will acknowledge and process your request within 40 days as required by the Ordinance.
• (b) Reasonable Fee: In accordance with the PDPO, We reserve the right to charge a reasonable fee for the processing of any Data Access Request to cover our administrative and labor costs in retrieving and preparing the data.

7. CONTACT US

If You have any questions regarding this Privacy Policy or wish to exercise Your rights, please address Your enquiry to:

• Company: 01 Festivals Limited
• Email: info@01festivals.com